1. YOUR PERSONAL DATA
The Data Subject, Controller and Processor for Personal Data
For the purposes of the General Data Protection Regulation (GDPR), Fello will be either the “Data Processor” or “Data Controller” for any Personal Data provided to us.
The Data Subject’s employer is the Data Controller for these purposes. The Data Controller is the Client Company of Fello, and Fello in turn acts as the Processor of the Data Subject’s Personal Data. Pursuant to a written contract with the Data Controller, Fello as Processor, will use the Personal Data of the Data Subject, provided by the Client Company, to facilitate travel arrangements for the Data Subject. It is this contract of service which forms the ‘Legal Basis’ for the processing of Personal Data carried out by Fello. (Further information on ‘Legal Basis’ is set out in the appendix to this document.)
There are circumstances where Fello may also become a Data Controller. If Fello collects additional Personal Data directly from a Data Subject, Fello will be acting under a ‘Legitimate Interest’ to legally process the data to facilitate travel arrangements for the Data Subject and to fulfil the contractual requirements for its Client Company. In circumstances where Fello collects Personal Data from the Data Subject, Fello will obtain that Data Subject’s express consent. Fello also acts as a Data Controller for any Personal Data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.
2. PERSONAL DATA WE COLLECT ABOUT YOU
The Personal Data we collect about you will only be the data specifically required to fulfil travel, accommodation, or other travel-related arrangements. Such data may be collected directly from you or provided to Fello via your employer. Such data will only be processed for that purpose. Certain kinds of Personal Data collected, such as data about your racial or ethnic origin, physical or mental health, or religious beliefs requires additional protection. By providing any sensitive data of this kind you agree that we may collect it and use it to provide our services.
3. HOW WE USE YOUR PERSONAL DATA
Fello has adopted the following principles to govern its processing and use of your Personal Data. Fello is committed to ensuring that the Personal Data collected:
- Shall be processed lawfully, fairly, and in a transparent manner;
- Is retained for as long as it is required to fulfil our contractual requirements, or to provide statistics to our Client Company;
- Is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is collected and/or processed;
- Is accurate and, where necessary, kept up to date; and
- Will not be used by Fello for any monitoring or profiling activity or process, and will not adopt any automated decision making processes
4. HOW WE PROTECT YOUR PERSONAL DATA
Fello protects your Personal Data against unauthorised access, unlawful use, accidental loss, corruption or destruction. We use technical measures such as encryption and password protection to protect your data. We also use operational measures to protect the data, for example by restricting access to only those in personnel who need to access your data.
Mindful of technological development, we keep these security measures under review and Fello may therefore need to implement adequate alternative technical and organisational measures.
5. DATA RETENTION
We keep your data for however long it is necessary to fulfil the purposes for which it was collected. This retention period may vary. For example, if you have an account with us, we will keep your data while your account is active for as long as it is needed to provide our services to you
6. YOUR RIGHTS
As a Data Subject you have the rights set out in chapter 3 GDPR. Fello will always fully respect your rights regarding the processing of your Personal Data, and has provided below at section 10 the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.
In summary, you are entitled to know who has your Personal Data, what they are using it for, to see copies of all Personal Data held by Fello and to amend, correct or delete such data. You may also limit, restrict or object to the processing of your data. In each case, the request must be in writing to Fello using the details set out at section 10 below.
For example, most travel bookings must be made under the traveller's full name and must include contact details and appropriate identification (e.g. passport details). Fello cannot make bookings for you without this information.
7. SHARING YOUR DATA
Transfers to Third Parties
To fulfil your travel arrangements, it will in most cases be necessary for Fello to process Personal Data via a third party (these include but are not limited to airlines, hotels, car hire companies, and Visa or Passport companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of the travel arrangements.
Sending data outside of the European Union
Fello will not transfer Personal Data to a country or territory outside the European Economic Area
(EEA) unless the transfer is made to a country or territory recognised by the EU as having an adequate
level of Data Security, or is made with your consent, or is made to satisfy the legitimate interest of Fello in
regard to its contractual arrangements with its clients.
All internal group transfers of Personal Data shall be subject to written agreements under Fello’s Intra Group Data Transfer Agreement (IGDTA) for internal Data transfers which are based on Standard Contractual Clauses recognised by the European Data Protection Authority.
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